12.6.5 Concluding remarks

Section 12.5 already highlighted the relevance of the 2013 Banking Communication for the burden-sharing by shareholders. The 2013 Banking Communication is equally relevant for the burden-sharing by subordinated debt holders. Indeed, this Communication establishes clear burden-sharing requirements. For that reason, a distinction can be made between the period after the adoption of the 2013 Banking Communication and the pre-2013 Banking Communication era. While in the pre-2013 Banking Communication era, several indications can be found that point at an inconsistent application of the burden-sharing principle, there are no such inconsistencies in the period after the adoption of the 2013 Banking Communication (see subsection 12.6.3.5).